# Justice Helen Zukin

*legal · Court of Appeal, Second Appellate District retention · judge* — November 3, 2026 General Election (2026-11-03), Los Angeles County, California

Research pack generated 2026-10-30T23:52:30+00:00 by ballotscope. Summaries are LLM-generated from the linked originals and may contain errors; check the originals before relying on anything. Sources span 2025-02-27 to 2026-10-14.

## Overview (as of 2026-10-29, from 17 sources)

Zukin has presided over Division Four since June 2025, after two years as an associate justice and five on the LA Superior Court; before that she was a plaintiffs' product-liability lawyer  [Presiding Justice Helen Zukin; Governor Newsom announces judicial appointments 5.7.25; Commission Confirms Appointments to Appellate Court in Los Angeles]. LAist reports a 2025 JNE rating of "exceptionally well qualified"  [2026 election: Court of Appeal justices on the LA and Orange County ballot]. From October 2024 to October 2026 she authored 7 published opinions in 5 cases, all civil, and wrote no dissents or concurrences  [Published opinions by Helen Zukin, October 2024 to October 2026 (courts.ca.gov listings)]. Her opinions read statutes closely and leave policy to the Legislature: a deputy who proved retaliation but lost to the County's same-decision defense could not recover fees  [Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin)]; a named trustee may petition in probate  [Estate of Tarlow (B333665, 2025-02-27; opinion by Helen Zukin)]; a non-buyer spouse cannot sue under the lemon law, but an insurance payout cannot cut the buyer's restitution  [Towns v. Hyundai Motor America, B324360 (2d Dist., Div. 4, 12/22/25), opinion by Zukin, P. J.; Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin)]; California exemption law governs collection against an out-of-state debtor  [Bagby v. Davis (B333649, 2026-02-17; opinion by Helen Zukin)]. In August 2026, her most recent, she fined a lawyer for baseless bias accusations against a trial judge  [A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J.]. DSA-LA and the cahighways blog lean retain; Reform California says do not retain, giving no reason  [Reform California voter guide: Los Angeles County; November 2026 General Election Ballot Analysis (IV): Judicial Offices; DSA-LA 2026 General Election Voter Guide].

### Record highlights
- Published-opinion census, Oct. 2024 to Oct. 2026: 7 authored opinions in 5 distinct cases (Towns listed three times), 0 dissents or concurrences; all civil; published opinions only. [Published opinions by Helen Zukin, October 2024 to October 2026 (courts.ca.gov listings)]
- Aug. 4, 2026, A Company Hungary v. Bespalov: held an attorney in direct contempt and fined him $1,000 for 26 unsupported accusations of trial-judge bias; published "as a warning." [A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J.]
- Feb. 17, 2026, Bagby v. Davis: affirmed a creditor's levy on a Florida resident's IRAs; forum-state exemption law applies, and a voluntarily surrendered life insurance policy is treated as matured. [Bagby v. Davis (B333649, 2026-02-17; opinion by Helen Zukin)]
- Dec. 22, 2025, Towns v. Hyundai: a non-buyer spouse lacks Song-Beverly standing; insurance proceeds cannot offset restitution; damages corrected to $24,085.83. On Jan. 16, 2026 the panel fixed misdated footnotes, denied rehearing, and published the whole opinion, including the holding that prejudgment interest is available. [Towns v. Hyundai Motor America, B324360 (2d Dist., Div. 4, 12/22/25), opinion by Zukin, P. J.; Towns v. Hyundai Motor America (B324360M, 2026-01-16; opinion by Helen Zukin); Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin)]
- July 8, 2025, Lampkin v. County of Los Angeles: reversed a $400,000 fee award and costs to a sheriff's deputy who proved whistleblower retaliation but obtained no relief because of the County's same-decision defense; declined to extend Harris v. City of Santa Monica. [Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin)]
- Feb. 2025, Estate of Tarlow: held a trustee named in a will has standing to petition for determination of estate distribution; reversed and remanded. [Estate of Tarlow (B333665, 2025-02-27; opinion by Helen Zukin)]
- Confirmed unanimously as Presiding Justice of Division Four on June 24, 2025. [Governor Newsom announces judicial appointments 5.7.25; Commission Confirms Appointments to Appellate Court in Los Angeles]

### Stated positions
- In her opinions (2025-26): standing and remedies come from the statute invoked, courts may not add exceptions to a statutory formula, and prior cases are not authority for issues they did not decide. [Estate of Tarlow (B333665, 2025-02-27; opinion by Helen Zukin); Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin); Towns v. Hyundai Motor America, B324360 (2d Dist., Div. 4, 12/22/25), opinion by Zukin, P. J.]
- In Lampkin (2025): extending FEHA's fee rule to whistleblower cases may be a rational policy choice, but one for the Legislature. [Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin)]
- In Bespalov (2026): an adverse ruling is not evidence of bias, and lawyers may not accuse judges of bias without evidence. [A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J.]

### Gaps
- No dissents or concurrences, so the record shows no view she held apart from her panel.
- No criminal or constitutional-rights opinions among her published work in the period.
- Unpublished opinions, the bulk of appellate work, are not covered.
- The September 2026 recusal request in Doe v. David appears only in the blog and is uncorroborated.
- No statements in her own words outside opinions.

### Arguments for / praise
- Rated "exceptionally well qualified" in the 2025 State Bar evaluation, as LAist reports. — *LAist* [2026 election: Court of Appeal justices on the LA and Orange County ballot]
- Retain: no misconduct, a sanctions opinion defending trial judges, and past leadership of the State Bar's judicial-evaluation commission. The blog attributes these facts to 'Google AI.' — *cahighways.org (Daniel Faigin)* [November 2026 General Election Ballot Analysis (IV): Judicial Offices]
- Probably yes: a plaintiff-side career suing corporations over defective products. — *DSA-LA* [DSA-LA 2026 General Election Voter Guide]

### Arguments against / criticism
- Do not retain (no reason given; same advice for all but three Second District justices). — *Reform California* [Reform California voter guide: Los Angeles County]

## Analysis of their own words (as of 2026-10-29)

Coverage: Systematic sample by a fixed rule: from the court's published-opinion listings (Oct 2024 to Oct 2026), her separate opinions newest first (up to 3; she wrote none), then her most recent authored opinions, five texts in all, counted by case. Five authored published opinions, Feb. 2025 to Aug. 2026: an attorney-sanctions opinion (S1, Bespalov), a judgment-collection appeal (S2, Bagby), a lemon-law appeal stored with its modification and publication orders (S3, Towns), a whistleblower attorney's-fee appeal (S4, Lampkin), and a probate standing appeal (S5, Tarlow). All civil and unanimous. These five are every case on her listing. No criminal cases, dissents, speeches, or interviews.

Text-first and record-bound. She reads statutory terms as written ('buyer,' the restitution formula, 'successful action,' 'entitled to distribution'), lets the statute invoked define standing and remedies, and declines to add exceptions or import rules from other statutes (S3, S4, S5). She checks readings against purpose and absurd-results canons (S2) and treats precedent as limited to what it decided (Patel in S3, Harris in S4). Policy choices go to the Legislature even when she calls the other side's policy rational (S4). She holds parties to burdens of proof and forfeiture (S2, S3) and sanctions lawyers who accuse judges of bias without evidence (S1). Outcomes do not run one way: a consumer won full restitution while the non-buyer spouse lost standing (S3); a creditor beat a debtor's exemption claims (S2); a deputy who proved retaliation lost his fee award to the County (S4); a trustee won standing against the beneficiaries (S5). The sample is too small for an ideological label.

Articulation: **strong**. Prepared texts only. Each opinion opens by stating the question and the answer in a few sentences (S3, S4, S5), lays out the governing test, and answers each argument in turn. Statutory reasoning is concrete: S2 traces the 1982 life-insurance exemption scheme; S4 gives four distinct reasons Harris does not govern. She tests the opposing side's policy argument rather than dismissing it ('the argument that full recovery would be a windfall for Towns and Johnson cuts both ways,' S3; extending Harris 'would be a rational policy choice,' S4). One slip: the Towns opinion's footnote 5 put the 2018 events in 2023, corrected by the modification order filed with it (S3).

Consistency: **adequate**. Five cases on unrelated subjects, so no single position can be compared over time. Method is uniform across 18 months: the statute invoked defines the right (S3, S4, S5), precedent is limited to the question it decided (Harris in S4, July 2025; Patel in S3, January 2026, citing the same McConnell rule), and arguments not raised below or raised first on reply are forfeited (S2, S3). No shifts found.

- Accusations of judicial bias by lawyers: An adverse ruling is not evidence of bias; accusing a judge without record evidence is sanctionable contempt, though vigorous disagreement is welcome.
  - "An adverse ruling is not evidence of judicial bias. And lawyers may not accuse a judge of bias without evidence." [A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J.] (2026-08-04)
  - "Counsel are obviously free to disagree with a ruling, and they are encouraged to explain in an appellate brief, with vim and vigor, why that ruling is wrong." [A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J.] (2026-08-04)
- Statutory remedies under the Song-Beverly Act: Only a 'buyer' may sue, and courts may not add offsets to the statutory restitution formula; the claim arises from the statute, so prejudgment interest under Civil Code section 3288 is available.
  - "Section 1793.2, subdivision (d)(2) provides a specific formula for calculating damages, and courts may not add exceptions to that formula." [Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin)] (2026-01-16)
  - "Patel does not authorize a non-buyer to bring suit under the Act." [Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin)] (2026-01-16)
  - "This action was governed by statute, not contract, from beginning to end." [Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin)] (2026-01-16)
- Attorney's fees in whistleblower cases: An employee who proves retaliation but loses to the employer's same-decision defense obtains no relief and so has not brought a 'successful action'; Harris's FEHA rule does not carry over.
  - "Nor do we see how a plaintiff may be deemed “successful” in an action where he obtains no relief." [Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin)] (2025-07-08)
  - "Where the complete set of instructions provides for a defense and does not limit its reach, the natural inference is that no such limitations exist." [Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin)] (2025-07-08)
- Probate standing: A trustee named in a will may petition to determine entitlement to the estate; the beneficiary's disclaimer goes to the merits, not standing.
  - "Probate proceedings are statutory in nature, and standing is determined by the applicable statute." [Estate of Tarlow (B333665, 2025-02-27; opinion by Helen Zukin)] (2025-02-27)
- Judgment collection and exemptions: The forum's exemption law governs regardless of the debtor's domicile; a voluntarily surrendered life insurance policy is treated as matured, and the debtor must prove an exemption.
  - "Here we hold California law applies to collection actions in California courts, regardless of where the judgment debtor lives." [Bagby v. Davis (B333649, 2026-02-17; opinion by Helen Zukin)] (2026-02-17)
  - "Funds cannot carry an exemption with them if they have no exemption to carry." [Bagby v. Davis (B333649, 2026-02-17; opinion by Helen Zukin)] (2026-02-17)

Limitations: Published opinions are a minority of a justice's work; most decisions are unpublished, and opinions she joined but did not write are excluded. Opinions are panel products, and the text may not be hers alone. All five cases are civil, so nothing shows her approach to criminal law or constitutional rights, and with no separate opinions nothing shows how she writes in disagreement.

## Timeline (newest first)

- **2026-11-03** — Retention election (California Secretary of State)
- **2026-10-14** — Published: DSA-LA 2026 General Election Voter Guide (Democratic Socialists of America, Los Angeles)
- **2026-10-07** — Published: November 2026 General Election Ballot Analysis (IV): Judicial Offices (cahighways.org (Daniel Faigin))
- **2026-10-01** — Published: 2026 election: Court of Appeal justices on the LA and Orange County ballot (LAist)
- **2026-09** — Recusal request in Doe v. David sent to her (cahighways.org (Daniel Faigin))
- **2026-08-24** — Published: List of Judicial Candidates with Headings and Ballot Questions, General Election November 3, 2026 (California Secretary of State)
- **2026-08-04** — A Company Hungary KFT v. Bespalov (B336640A) filed (Judicial Branch of California)
- **2026-08-04** — Published: A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J. (California Court of Appeal, Second Appellate District)
- **2026-08-04** — Sanctions opinion filed (published) (California Court of Appeal, Second Appellate District)
- **2026-08** — Authored opinion imposing $1,000 sanction on an attorney (cahighways.org (Daniel Faigin))
- **2026-02-17** — Published: Bagby v. Davis (B333649, 2026-02-17; opinion by Helen Zukin) (California Court of Appeal, Second District, Division 4)
- **2026-02-17** — Opinion filed in Bagby v. Davis (B333649), affirming (California Court of Appeal, Second District, Division 4)
- **2026-02-17** — Bagby v. Davis (B333649) filed (Judicial Branch of California)
- **2026-01-20** — Towns v. Hyundai (B324360N) filed (Judicial Branch of California)
- **2026-01-16** — Towns v. Hyundai (B324360M) filed (Judicial Branch of California)
- **2026-01-16** — Published: Towns v. Hyundai Motor America (B324360M, 2026-01-16; opinion by Helen Zukin) (California Court of Appeal, Second District, Division 4)
- **2026-01-16** — Order modifying Towns v. Hyundai opinion and denying rehearing (California Court of Appeal, Second District, Division 4)
- **2026-01-16** — Published: Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin) (California Court of Appeal, Second District, Division 4)
- **2026-01-16** — Order publishing the entire Towns v. Hyundai opinion (California Court of Appeal, Second District, Division 4)
- **2026-01-16** — Order modifying opinion and denying rehearing (California Court of Appeal, Second District, Division 4)
- **2025-12-22** — Published: Towns v. Hyundai Motor America, B324360 (2d Dist., Div. 4, 12/22/25), opinion by Zukin, P. J. (California Court of Appeal, Second Appellate District)
- **2025-12-22** — Opinion filed (partially published) (California Court of Appeal, Second Appellate District)
- **2025-12-22** — Towns v. Hyundai (B324360) filed (Judicial Branch of California)
- **2025-12-22** — Original Towns v. Hyundai opinion filed (California Court of Appeal, Second District, Division 4)
- **2025-07-08** — Lampkin v. County of Los Angeles (B336806) filed (Judicial Branch of California)
- **2025-07-08** — Published: Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin) (California Court of Appeal, Second District, Division 4)
- **2025-07-08** — Court of Appeal reverses fee and cost awards (California Court of Appeal, Second District, Division 4)
- **2025-06-24** — Published: Commission Confirms Appointments to Appellate Court in Los Angeles (California Courts Newsroom)
- **2025-06-24** — Confirmed as Presiding Justice (California Courts Newsroom)
- **2025-05-07** — Published: Governor Newsom announces judicial appointments 5.7.25 (Office of Governor Gavin Newsom)
- **2025-05-07** — Nominated as Presiding Justice (Office of Governor Gavin Newsom)
- **2025-02-27** — Published: Estate of Tarlow (B333665, 2025-02-27; opinion by Helen Zukin) (California Court of Appeal, Second District, Division 4)
- **2025-02-27** — Opinion certified for publication (California Court of Appeal, Second District, Division 4)
- **2025-02-27** — Estate of Tarlow (B333665) filed (Judicial Branch of California)
- **2025-02-20** — Opinion filed (unpublished) (California Court of Appeal, Second District, Division 4)
- **2025** — Became Presiding Justice (California Courts of Appeal)
- **2024-03-08** — Trial court awards Lampkin $400,000 in attorney's fees (California Court of Appeal, Second District, Division 4)
- **2023-07** — Joined Court of Appeal (California Courts of Appeal)
- **2023-02-10** — Jury special verdict: retaliation shown, same-decision defense established, no damages (California Court of Appeal, Second District, Division 4)
- **2018** — Appointed to LA Superior Court (California Courts of Appeal)

## Sources

### DSA-LA 2026 General Election Voter Guide
- Democratic Socialists of America, Los Angeles · endorsement · published 2026-10-14 · stance: support
- <https://dsa-la.org/wp-content/uploads/2026/10/DSA-LA-2026-GENERAL-Voter-Guide.pdf>

DSA-LA's guide places Zukin among justices with "mostly inoffensive pre-appointment careers" whom voters "should probably vote yes on," noting she represented plaintiffs suing corporations for defective products.
  - DSA-LA: Zukin "specialized in plaintiff side civil legislation, suing corporations for shoddy products."

### November 2026 General Election Ballot Analysis (IV): Judicial Offices
- cahighways.org (Daniel Faigin) · voter guide · published 2026-10-07 · stance: support
- <https://cahighways.org/wordpress/?p=17921>

Blogger Daniel Faigin recommends Retain (Yes) for Zukin, relaying a 'Google AI' summary: no misconduct; an August 2026 opinion she wrote sanctioning a lawyer $1,000 for unsupported bias accusations; her past chairing of the State Bar's JNE Commission; and a September 2026 recusal request in Doe v. David.
  - Conclusion: Retain (Yes).
  - Cites her August 2026 sanctions opinion against a lawyer who "accused a lower trial judge of bias without evidence."
  - Says a recusal request in Jane Doe v. Alkiviades David (Sept. 2026) does not imply wrongdoing.

### 2026 election: Court of Appeal justices on the LA and Orange County ballot
- LAist · voter guide · published 2026-10-01 · stance: neutral
- <https://laist.com/news/politics/voter-guides/2026-election-california-general-courts-appeal-justice-la-orange-county>

LAist explainer on Court of Appeal retention races; its Second District roster lists Helen Zukin with a 2025 State Bar evaluation rating of "Exceptionally well qualified" and appointment by Gov. Newsom. No individual discussion.
  - LAist lists the State Bar (JNE) evaluation rating (2025) as "Exceptionally well qualified".
  - Retention questions are yes/no; per a state analysis LAist cites, no California appellate justice has lost a retention election since the system began in the 1930s.
  - Appellate justices sit on three-member panels reviewing lower-court decisions; they do not retry facts.

### List of Judicial Candidates with Headings and Ballot Questions, General Election November 3, 2026
- California Secretary of State · official analysis · published 2026-08-24 · stance: not_applicable
- <https://elections.cdn.sos.ca.gov/statewide-elections/2026-general/judicial.pdf>

Official certified list of judicial contests for Nov. 3, 2026; confirms Presiding Justice Helen Zukin (Division Four) is on the Second District retention ballot.
  - Ballot question: "Shall Presiding Justice HELEN ZUKIN be elected to the office for the term provided by law?"

### A Company Hungary KFT v. Bespalov, B336640A (2d Dist., Div. 4, 8/4/26), sanctions opinion by Zukin, P. J.
- California Court of Appeal, Second Appellate District · court opinion · published 2026-08-04 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/documents/B336640A.PDF>

Published opinion by Zukin (Mori, Tamzarian concurring) holding attorney Jeremiah Reynolds in direct contempt and fining him $1,000 for 26 unsupported accusations of trial-judge bias in appellate briefs; published "as a warning."
  - Opening: "An adverse ruling is not evidence of judicial bias.  And lawyers may not accuse a judge of bias without evidence."
  - Found counsel's apology "immediately qualified and tacitly retracted" by defending his conduct.
  - Ordered the opinion forwarded to the State Bar; merits resolved in a separate unpublished opinion.

### Bagby v. Davis (B333649, 2026-02-17; opinion by Helen Zukin)
- California Court of Appeal, Second District, Division 4 · court opinion · published 2026-02-17 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/archive/B333649.PDF>

Published opinion by Zukin (Collins, Tamzarian concurring) affirming an order letting a judgment creditor levy on a Florida-resident debtor's IRAs: California exemption law governs collection in California courts, and a voluntarily surrendered life insurance policy is treated as matured, so its proceeds are exempt only if needed for support.
  - Holds claims of exemption are decided under the law of the forum state, following Division Four's 1977 DeLotel decision; the debtor's domicile is irrelevant.
  - Funds in an account are intangible and located wherever the court has jurisdiction over the custodian; the debtor never contested jurisdiction over LPL.
  - New rule: a voluntarily surrendered life insurance policy is treated as matured, because treating it as unmatured would make the creditor's statutory right to loan value uncollectible.
  - The debtor failed to prove the source plan was designed and used for retirement: he borrowed about a third of its single asset and let another third go to unpaid interest, without explanation.
  - Several arguments (funds located in South Carolina, writ expiration, tax holdback) held forfeited for not being raised below.

### Towns v. Hyundai Motor America (B324360M, 2026-01-16; opinion by Helen Zukin)
- California Court of Appeal, Second District, Division 4 · court opinion · published 2026-01-16 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/archive/B324360M.PDF>

Order by the Zukin panel (Zukin, Collins, Tamzarian) modifying the December 22, 2025 Towns v. Hyundai opinion and denying Hyundai's rehearing petition, with the unmodified opinion attached. The only change corrects three dates in footnote 5 from 2023 to 2018; the judgment is unchanged.
  - Corrects footnote 5 dates (May 30 and April 11) from 2023 to 2018, the year of the events.
  - Hyundai's petition for rehearing denied; no change in judgment.
  - The attached opinion (by Zukin) holds a non-buyer spouse lacks standing under the Song-Beverly Act and that an insurance payout cannot offset statutory restitution.

### Towns v. Hyundai Motor America (B324360N, 2026-01-20; opinion by Helen Zukin)
- California Court of Appeal, Second District, Division 4 · court opinion · published 2026-01-16 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/archive/B324360N.PDF>

The same January 16, 2026 modification order in Towns v. Hyundai, plus a separate order that day publishing the whole opinion, including the formerly unpublished holding that Song-Beverly obligations arise from the statute, not contract, so prejudgment interest is available under Civil Code section 3288.
  - Publication ordered on requests from Cynthia E. Tobisman of Greines, Martin, Stein & Richland (plaintiffs' appellate counsel) and Jordan G. Cohen.
  - Newly published part: the claim was 'governed by statute, not contract, from beginning to end,' so section 3288 interest applies.
  - Rejects Hyundai's argument that a breach-of-warranty label makes the claim contractual, saying it 'elevates the label over the substance.'
  - Several Hyundai arguments raised first on reply held forfeited.

### Towns v. Hyundai Motor America, B324360 (2d Dist., Div. 4, 12/22/25), opinion by Zukin, P. J.
- California Court of Appeal, Second Appellate District · court opinion · published 2025-12-22 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/archive/B324360.PDF>

Partially published opinion by Zukin (Collins, Tamzarian concurring) in a Song-Beverly lemon-law case: a non-buyer spouse lacks standing, and an insurance payout after the car was totaled may not offset the manufacturer's restitution.
  - Held the trial court "stretched Patel too far"; the Act lets only a "buyer" sue, and the record did not support a "de facto buyer."
  - Applied Niedermeier: the statutory restitution formula has no exception for insurance payments; damages corrected to $24,085.83.
  - Unpublished part: prejudgment interest available under Civ. Code § 3288 because the obligations arise from the Act, not contract.

### Lampkin v. County of Los Angeles (B336806, 2025-07-08; opinion by Helen Zukin)
- California Court of Appeal, Second District, Division 4 · court opinion · published 2025-07-08 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/archive/B336806.PDF>

Zukin's unanimous opinion reverses a $400,000 attorney's-fee award and costs to a sheriff's deputy who proved whistleblower retaliation but lost to the County's "same-decision" defense. It holds a plaintiff who obtains no relief has not brought a "successful action" under Labor Code section 1102.5(j), and declines to extend the Supreme Court's FEHA decision in Harris v. City of Santa Monica.
  - The jury found Deputy D'Andre Lampkin's protected activity was a factor in LASD's actions but that LASD would have acted the same anyway, so no damages.
  - Harris is distinguished: different procedural posture, FEHA's discretionary prevailing-party fee clause, and section 1102.6's "complete set of instructions."
  - Follows Ververka (2024), the only case on the effect of a section 1102.6 defense.
  - The County, not Lampkin, is the prevailing party for costs under Code Civ. Proc. section 1032.
  - Says extending Harris "would be a rational policy choice" but leaves it to the Legislature.

### Commission Confirms Appointments to Appellate Court in Los Angeles
- California Courts Newsroom · news · published 2025-06-24 · stance: neutral
- <https://courts.ca.gov/news/commission-confirms-appointments-appellate-court-los-angeles>

Judicial Council release: the Commission on Judicial Appointments unanimously confirmed Zukin as Presiding Justice of Division Four on June 24, 2025.
  - Unanimous vote of Chief Justice Guerrero, AG Bonta and Presiding Justice Gilbert.

### Governor Newsom announces judicial appointments 5.7.25
- Office of Governor Gavin Newsom · news · published 2025-05-07 · stance: neutral
- <https://www.gov.ca.gov/2025/05/07/governor-newsom-announces-judicial-appointments-5-7-25/>

Governor's release nominating Associate Justice Zukin as Presiding Justice of Division Four, succeeding Brian Currey, with career dates and party (Democrat).
  - Associate Justice in Division Four since 2023; LA Superior Court judge 2018-2023; Kiesel Law partner 2006-2018; solo practice 1995-2006.

### Estate of Tarlow (B333665, 2025-02-27; opinion by Helen Zukin)
- California Court of Appeal, Second District, Division 4 · court opinion · published 2025-02-27 · stance: not_applicable
- <https://www.courts.ca.gov/opinions/archive/B333665.PDF>

Zukin's opinion (as Acting Presiding Justice, unanimous) holds that a trustee named in a will has standing under Probate Code section 11700 to petition for a determination of who is entitled to the estate, reversing a demurrer ruling against trustee David Simon. Filed unpublished Feb. 20, 2025, and certified for publication on the court's own motion Feb. 27.
  - A trustee named in a will is a "devisee" and so a "person claiming to be . . . entitled to distribution" under section 11700.
  - Standing is defined by the statute invoked; section 48's "interested person" definition does not apply because that term is not in section 11700.
  - A presumption that a beneficiary's disclaimer is valid cannot be applied on demurrer; the disclaimer's validity goes to the merits, not standing.
  - The court expressly expresses no view on the disclaimer or on the beneficiary's $100,000 purchase of a charity's remainder interest, and remands.

### Published opinions by Helen Zukin, October 2024 to October 2026 (courts.ca.gov listings)
- Judicial Branch of California · decision record · published undated · stance: not_applicable
- <https://courts.ca.gov/opinions/published-opinions-older-120-days>

Census of Zukin's published opinions, Oct. 2024 to Oct. 2026, from courts.ca.gov listings: 7 authored, 0 dissents or concurrences. All seven are civil; three entries are one case, Towns v. Hyundai (original, modification, publication order).
  - 7 authored published opinions; 0 separate opinions.
  - Distinct cases: A Company Hungary v. Bespalov (attorney sanctions, 2026), Bagby v. Davis (judgment collection, 2026), Towns v. Hyundai (lemon law, 2025-26), Lampkin v. County of Los Angeles (2025), Estate of Tarlow (probate, 2025).
  - Covers published opinions only; most appellate decisions are unpublished.

### Reform California voter guide: Los Angeles County
- Reform California · voter guide · published undated · stance: oppose
- <https://www.reformcalifornia.org/voter-guides/los-angeles>

Conservative group Reform California's LA County slate recommends DO NOT RETAIN for Helen Zukin, as it does for nearly every Second District justice (retain only Chavez, Rothschild, Yegan). No reasons are given for any justice.
  - Recommendation: Helen Zukin — DO NOT RETAIN.
  - Same recommendation for all but three of the listed Second District justices.

### Presiding Justice Helen Zukin
- California Courts of Appeal · other · published undated · stance: not_applicable
- <https://appellate.courts.ca.gov/district-courts/2dca/bio/helen-zukin>

Court biography: on the Court of Appeal since July 2023, Presiding Justice of Division Four since 2025; LA Superior Court judge 2018-2023; earlier a plaintiffs' complex-litigation lawyer (toxic torts, pharmaceutical and device, product liability).
  - Helped establish LA Superior Court's Judicial Mentor Program; co-chairs the Appellate Judicial Mentor Program.
  - Former chair of the State Bar's Commission on Judicial Nominees Evaluation (JNE) and of several judicial-selection panels; former president of the Los Angeles Ethics Commission.
  - Partner at Kiesel Law (2010); former board member of Consumer Attorneys Association of Los Angeles.

### Official Voter Information Guide: Second District Court of Appeal justices
- California Secretary of State · official analysis · published undated · stance: neutral
- <https://voterguide.sos.ca.gov/justices/courts-of-appeal/district2.htm>

Secretary of State voter-guide index of Second District justices on the ballot; lists Helen Zukin under Division Four and links to court biographies. Contains no evaluation.
  - Lists Helen Zukin among the Division Four justices on the ballot.

### Justice Zukin helped build state's judicial mentor program, faces first retention vote
- Daily Journal · news · published undated · stance: neutral
- <https://www.dailyjournal.com/articles/395080-justice-zukin-helped-build-state-s-judicial-mentor-program-faces-first-retention-vote>

## Suggested use

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